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MONTHYEARML13123A0952013-05-0202 May 2013 10 CFR 50.55a Request: Proposed Alternative to ASME Section Xi Requirements for Leakage Testing of Reactor Pressure Vessel Head Flange Leakoff Lines (Relief Request 13R-14) Project stage: Request ULNRC-05990, Supplemental Information for 10 CFR 50.55a Request: Proposed Alternative to ASME Section XI Requirements for Leakage Testing of Reactor Pressure Vessel Head Flange Leakoff Lines (Relief Request I3R-14)2013-05-0606 May 2013 Supplemental Information for 10 CFR 50.55a Request: Proposed Alternative to ASME Section XI Requirements for Leakage Testing of Reactor Pressure Vessel Head Flange Leakoff Lines (Relief Request I3R-14) Project stage: Supplement ML13126A3202013-05-0707 May 2013 Summary of Telephone Conference, Verbal Authorization of Relief Request I3R-14. Proposed Alternative to ASME Code Requirements for Leakage Testing of RPV Head Flange Leakoff Lines, Third 10-Year ISI Interval. Project stage: Other ML13136A0592013-05-17017 May 2013 Request for Additional Information, Relief Request I3R-14, Proposed Alternative to ASME Code Requirements for Leakage Testing of RPV Head Flange Leakoff Lines, Third 10-Year Inservice Inspection Interval Project stage: RAI ULNRC-06012, Response to Request for Additional Information Regarding Relief Request 13R-14, Proposed Alternative to ASME Code, Section XI Requirements for Leakage Testing of Reactor Pressure Vessel Head Flange Leakoff Lines2013-07-0303 July 2013 Response to Request for Additional Information Regarding Relief Request 13R-14, Proposed Alternative to ASME Code, Section XI Requirements for Leakage Testing of Reactor Pressure Vessel Head Flange Leakoff Lines Project stage: Response to RAI ML13221A0912013-08-13013 August 2013 Relief Request I3R-14, Proposed Alternative to ASME Code Requirements for Leakage Testing of RPV Head Flange Leakoff Lines, Third 10-Year Inservice Inspection Interval Project stage: Other 2013-05-06
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Category:Letter type:ULNRC
MONTHYEARULNRC-06853, Submittal of 2023 Fitness for Duty Performance Data Per Per 10 CFR 26.7172024-01-29029 January 2024 Submittal of 2023 Fitness for Duty Performance Data Per Per 10 CFR 26.717 ULNRC-06847, Supplement to Relief Request from Requirements of ASME BPV Code, Section XI, Subsection Iwl Regarding Examination and Testing of the Unbonded Post-Tensioning System (Relief Request C3R-01)2023-12-21021 December 2023 Supplement to Relief Request from Requirements of ASME BPV Code, Section XI, Subsection Iwl Regarding Examination and Testing of the Unbonded Post-Tensioning System (Relief Request C3R-01) ULNRC-06849, License Renewal Resolution for Commitments 34 and 35 Perform Evaluation of Crack Initiation and Propagation in Steam Generator Divider Plate and Tube-To-Tubesheet Welds2023-12-20020 December 2023 License Renewal Resolution for Commitments 34 and 35 Perform Evaluation of Crack Initiation and Propagation in Steam Generator Divider Plate and Tube-To-Tubesheet Welds ULNRC-06844, Request for Exemption from Specific Requirements in 2023 Security Rule, Enhanced Weapons, Firearms Background Checks, and Security Event Notification2023-12-0707 December 2023 Request for Exemption from Specific Requirements in 2023 Security Rule, Enhanced Weapons, Firearms Background Checks, and Security Event Notification ULNRC-06827, Supplement to License Amendment Request Regarding Support System Requirements for Residual Heat Removal and Control Room Air Conditioning Systems Under Technical Specifications 3.4.8, 3.7.11, and 3.9.6 (LDCN 22-0029)2023-11-20020 November 2023 Supplement to License Amendment Request Regarding Support System Requirements for Residual Heat Removal and Control Room Air Conditioning Systems Under Technical Specifications 3.4.8, 3.7.11, and 3.9.6 (LDCN 22-0029) ULNRC-06824, Response to Request for Additional Information Regarding Operating Quality Assurance Manual (Oqam) Revision 36A2023-08-17017 August 2023 Response to Request for Additional Information Regarding Operating Quality Assurance Manual (Oqam) Revision 36A ULNRC-06830, Transmittal of Updated Technical Specification Markup and Clean Pages for License Amendment Request to Revise Technical Specification 5.5.16, Containment Leakage Rate Testing Program, for Permanent Extension of Type a and Type C Leak2023-08-15015 August 2023 Transmittal of Updated Technical Specification Markup and Clean Pages for License Amendment Request to Revise Technical Specification 5.5.16, Containment Leakage Rate Testing Program, for Permanent Extension of Type a and Type C Leak ULNRC-06223, Minor Correction to License Amendment Request to Revise Technical Specification 5.5.16, Containment Leakage Rate Testing Program, for Permanent Extension of Type a and Type C Leak Rate Test Frequencies (LDCN 2020-0004)2023-07-25025 July 2023 Minor Correction to License Amendment Request to Revise Technical Specification 5.5.16, Containment Leakage Rate Testing Program, for Permanent Extension of Type a and Type C Leak Rate Test Frequencies (LDCN 2020-0004) ULNRC-06799, Submittal of Licensee Event Report 2022-003-01, Class 1E Electrical Air Conditioning System Thermal Expansion Valve Failure Resulted in Condition Prohibited by Technical Specifications2023-07-13013 July 2023 Submittal of Licensee Event Report 2022-003-01, Class 1E Electrical Air Conditioning System Thermal Expansion Valve Failure Resulted in Condition Prohibited by Technical Specifications ULNRC-06821, Post-Audit Follow-Up Information in Support of Callaway'S License Amendment Request and Proposed Exemption to Allow Use of Framatome Gaia Fuel (LDCN 22-0002) (EPID L-2022-LLA-0150 and EPID L-2022-LLE-00301)2023-06-21021 June 2023 Post-Audit Follow-Up Information in Support of Callaway'S License Amendment Request and Proposed Exemption to Allow Use of Framatome Gaia Fuel (LDCN 22-0002) (EPID L-2022-LLA-0150 and EPID L-2022-LLE-00301) ULNRC-06822, Additional Information Regarding Request for NRC Approval of Operating Quality Assurance Manual (Oqam) Revision 36a2023-06-14014 June 2023 Additional Information Regarding Request for NRC Approval of Operating Quality Assurance Manual (Oqam) Revision 36a ULNRC-06815, Request for NRC Approval of Operating Quality Assurance Manual, Revision 36a2023-06-0505 June 2023 Request for NRC Approval of Operating Quality Assurance Manual, Revision 36a ULNRC-06818, Response to Request for Additional Information Regarding License Amendment Request to Revise Technical Specification 5.5.16, Containment Leakage Rate Testing Program, for Permanent Extension of Type a and Type C Leak Rate .2023-06-0505 June 2023 Response to Request for Additional Information Regarding License Amendment Request to Revise Technical Specification 5.5.16, Containment Leakage Rate Testing Program, for Permanent Extension of Type a and Type C Leak Rate . ULNRC-06816, Withdrawal of Previously Submitted Enclosures Regarding License Amendment Request for Adoption of Alternative Source Term and Revision of Technical Specifications (LDCN 21-0015)2023-05-0909 May 2023 Withdrawal of Previously Submitted Enclosures Regarding License Amendment Request for Adoption of Alternative Source Term and Revision of Technical Specifications (LDCN 21-0015) ULNRC-06812, Submittal of 2022 Annual Radiological Environmental Operating Report2023-04-27027 April 2023 Submittal of 2022 Annual Radiological Environmental Operating Report ULNRC-06806, Submittal of Radiological Emergency Response Plan, Revision 552023-04-12012 April 2023 Submittal of Radiological Emergency Response Plan, Revision 55 ULNRC-06807, Submittal of Single Positive Test Forms2023-04-0303 April 2023 Submittal of Single Positive Test Forms ULNRC-06798, Submittal of Status of Plant Decommissioning Funding and ISFSI Decommissioning Funding Plan2023-03-30030 March 2023 Submittal of Status of Plant Decommissioning Funding and ISFSI Decommissioning Funding Plan ULNRC-06801, CFR 50.46 Annual Report Regarding ECCS Evaluation Model Revisions2023-03-30030 March 2023 CFR 50.46 Annual Report Regarding ECCS Evaluation Model Revisions ULNRC-06804, Submittal of Nuclear Property Insurance Reporting2023-03-29029 March 2023 Submittal of Nuclear Property Insurance Reporting ULNRC-06751, Application to Revise Technical Specifications to Adopt TSTF-501-A, Rev. 1, Relocate Stored Oil & Lube Oil Volume Values to Licensee Control2023-03-29029 March 2023 Application to Revise Technical Specifications to Adopt TSTF-501-A, Rev. 1, Relocate Stored Oil & Lube Oil Volume Values to Licensee Control ULNRC-06803, Submittal of Response to Request for Additional Information Regarding Results of Steam Generator Tube In-Service Inspection2023-03-29029 March 2023 Submittal of Response to Request for Additional Information Regarding Results of Steam Generator Tube In-Service Inspection ULNRC-06805, Transmittal of Special Report 2023-02 Non-Functionality of Containment Hydrogen Analyzer Channel for Greater than 30 Days2023-03-21021 March 2023 Transmittal of Special Report 2023-02 Non-Functionality of Containment Hydrogen Analyzer Channel for Greater than 30 Days ULNRC-06802, Special Report 2023-01 (PAM Report); Non-Functionality of a Post-Accident Monitoring Instrument2023-03-0909 March 2023 Special Report 2023-01 (PAM Report); Non-Functionality of a Post-Accident Monitoring Instrument ULNRC-06795, Submittal of Fitness for Duty Reports for 2022, Including Single Positive Test Forms2023-01-24024 January 2023 Submittal of Fitness for Duty Reports for 2022, Including Single Positive Test Forms ULNRC-06794, Submittal of Fitness for Duty Program Data for 20222023-01-24024 January 2023 Submittal of Fitness for Duty Program Data for 2022 ULNRC-06787, Response to Request for Additional Information Regarding License Amendment Request for Adoption of Alternate Source Term and Revision of Technical Specifications (LDCN 21-0015)2022-12-0808 December 2022 Response to Request for Additional Information Regarding License Amendment Request for Adoption of Alternate Source Term and Revision of Technical Specifications (LDCN 21-0015) ULNRC-06781, License Amendment Request to Clarify Support System Requirements for the Residual Heat Removal System and Control Room Air Conditioning System Under Technical Specifications 3.4.8, 3.7.11, and 3.9.6 (LDCN 22-0029)2022-12-0101 December 2022 License Amendment Request to Clarify Support System Requirements for the Residual Heat Removal System and Control Room Air Conditioning System Under Technical Specifications 3.4.8, 3.7.11, and 3.9.6 (LDCN 22-0029) ULNRC-06780, Additional Supplement to License Amendment Request to Adopt TSTF-439 and TSTF-505, LDCN 20-0072022-11-30030 November 2022 Additional Supplement to License Amendment Request to Adopt TSTF-439 and TSTF-505, LDCN 20-007 ULNRC-06772, 10 CFR 50.59 and 10 CFR 72.48 Summary Report2022-11-23023 November 2022 10 CFR 50.59 and 10 CFR 72.48 Summary Report ULNRC-06777, Operating Quality Assurance Manual (Oqam) Revision 362022-11-16016 November 2022 Operating Quality Assurance Manual (Oqam) Revision 36 ULNRC-06779, ULNRC-06779: Contesting of Green NCV 05000483/2022010-03, Failure to Perform Required Inservice Testing of Residual Heat Removal Heat Exchanger Pneumatically (Air) Operated Outlet and Bypass Valves2022-11-14014 November 2022 ULNRC-06779: Contesting of Green NCV 05000483/2022010-03, Failure to Perform Required Inservice Testing of Residual Heat Removal Heat Exchanger Pneumatically (Air) Operated Outlet and Bypass Valves ULNRC-06765, License Amendment Request to Revise Technical Specification 5.5.16, Containment Leakage Rate Testing Program, for Permanent Extension of Type a and Type C Leak Rate Testing Frequencies (LDCN 2020-0004)2022-11-0303 November 2022 License Amendment Request to Revise Technical Specification 5.5.16, Containment Leakage Rate Testing Program, for Permanent Extension of Type a and Type C Leak Rate Testing Frequencies (LDCN 2020-0004) ULNRC-06773, Results of Steam Generator Tube In-Service Inspection2022-11-0101 November 2022 Results of Steam Generator Tube In-Service Inspection ULNRC-06775, Submittal of Non-Functionality of Loose-Part Detection System Channel for Greater than 30 Days2022-10-27027 October 2022 Submittal of Non-Functionality of Loose-Part Detection System Channel for Greater than 30 Days ULNRC-06771, Correction to Application to Revise Technical Specifications to Adopt TSTF 577, Revised Frequencies for Steam Generator Tube Inspections (LDCN 21-0013)2022-10-25025 October 2022 Correction to Application to Revise Technical Specifications to Adopt TSTF 577, Revised Frequencies for Steam Generator Tube Inspections (LDCN 21-0013) ULNRC-06770, Cycle 25 Commitment Change Summary Report2022-10-19019 October 2022 Cycle 25 Commitment Change Summary Report ULNRC-06766, Correction of Text Contained in Enclosures Provided with Supplements to Request for License Amendment and Regulatory Exemptions for a Risk-Informed Approach to Address GSI-191 and Respond to GL 2004-02 (LDCN 19-0014)2022-09-0808 September 2022 Correction of Text Contained in Enclosures Provided with Supplements to Request for License Amendment and Regulatory Exemptions for a Risk-Informed Approach to Address GSI-191 and Respond to GL 2004-02 (LDCN 19-0014) ULNRC-06767, Presentation Information for Pre-Application Meeting Regarding New License Amendment Request for Use of Framatome Fuel Assemblies2022-09-0606 September 2022 Presentation Information for Pre-Application Meeting Regarding New License Amendment Request for Use of Framatome Fuel Assemblies ULNRC-06764, Revised Response to Request for Additional Information Regarding License Amendment Request for Adoption Off Alternate Source Term and Revision of Technical Specifications (LDCN 21-0015)2022-09-0101 September 2022 Revised Response to Request for Additional Information Regarding License Amendment Request for Adoption Off Alternate Source Term and Revision of Technical Specifications (LDCN 21-0015) ULNRC-06763, Supplement to Application to Revise Technical Specifications to Adopt TSTF 577, Revised Frequencies for Steam Generator Tube Inspection (LDCN 21-0013)2022-09-0101 September 2022 Supplement to Application to Revise Technical Specifications to Adopt TSTF 577, Revised Frequencies for Steam Generator Tube Inspection (LDCN 21-0013) ULNRC-06762, Submittal of Owner'S Activity Reports (OAR-1 Forms) for Cycle/Refuel 252022-08-25025 August 2022 Submittal of Owner'S Activity Reports (OAR-1 Forms) for Cycle/Refuel 25 ULNRC-06758, Union Electric Co. - Renewed Facility Operating License NPF-30, Withdrawal of License Amendment Request and Exemption Request Regarding Transition to Framatome Fuel (LDCN 22-0002)2022-08-0404 August 2022 Union Electric Co. - Renewed Facility Operating License NPF-30, Withdrawal of License Amendment Request and Exemption Request Regarding Transition to Framatome Fuel (LDCN 22-0002) ULNRC-06755, Response to Requests for Additional Information for Proposed Revision to Radiological Emergency Response Plan Regarding Response and Notification Goals2022-07-13013 July 2022 Response to Requests for Additional Information for Proposed Revision to Radiological Emergency Response Plan Regarding Response and Notification Goals ULNRC-06754, Response to Request for Additional Information Regarding Licensee Amendment Request for Adoption of Alternate Source Term and Revision of Technical Specifications2022-07-0505 July 2022 Response to Request for Additional Information Regarding Licensee Amendment Request for Adoption of Alternate Source Term and Revision of Technical Specifications ULNRC-06739, Post-Audit Supplement to License Amendment Request to Adopt TSTF-439 and TSTF-505 (LDCN 20-0007)2022-06-30030 June 2022 Post-Audit Supplement to License Amendment Request to Adopt TSTF-439 and TSTF-505 (LDCN 20-0007) ULNRC-06752, Evacuation Time Estimates Report2022-06-27027 June 2022 Evacuation Time Estimates Report ULNRC-06753, Presentation Information for Pre-Submittal Meeting Regarding Updated Spent Fuel Criticality Safety Analysis2022-06-23023 June 2022 Presentation Information for Pre-Submittal Meeting Regarding Updated Spent Fuel Criticality Safety Analysis ULNRC-06750, Submittal of Cycle 26 Core Operating Limits Report (COLR)2022-06-13013 June 2022 Submittal of Cycle 26 Core Operating Limits Report (COLR) ULNRC-06735, Response to Request for Additional Information Regarding Request for License Amendment and Regulatory Exemptions for Risk-Informed Approach to Address GSI-191 and Respond to Generic Letter 2004-02 (LDCN 19-0014).2022-05-27027 May 2022 Response to Request for Additional Information Regarding Request for License Amendment and Regulatory Exemptions for Risk-Informed Approach to Address GSI-191 and Respond to Generic Letter 2004-02 (LDCN 19-0014). 2024-01-29
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WAmeren Callaway Plant MISSOURI May 6, 2013 ULNRC-05990 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 10 CFR 50.55a Ladies and Gentlemen:
DOCKET NUMBER 50-483 CALLAWAY PLANT UNIT 1 UNION ELECTRIC CO.
FACILITY OPERATING LICENSE NPF-30 SUPPLEMENTAL INFORMATION FOR 10 CFR 50.55a REQUEST: PROPOSED ALTERNATIVE TO ASME SECTION XI REQUIREMENTS FOR LEAKAGE TESTING OF REACTOR PRESSURE VESSEL HEAD FLANGE LEAKOFF LINES (RELIEF REQUEST 13R-14)
Reference 1: Ameren Missouri Letter ULNRC-05986, "1 0 CFR 50.55a Request:
Proposed Alternative to ASME Section XI Requirements for Leakage Testing of Reactor Pressure Vessel Head Flange Leakoff Lines (Relief Request BR-14)," dated May 2, 2013 Pursuant to 10 CFR 50.55a(a)(3)(ii), and by letter dated May 2, 2013 (Reference 1), Ameren Missouri submitted Relief Request BR-14 in regard to the pressure at which leakage testing ofthe reactor pressure vessel head flange leakofflines must be perfonned, as specified per Paragraph IWC-5221 of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code,Section XI.
The relief is requested on the basis that compliance with the Code-specified pressure requirement to test the leakofflines at system operating pressure is impractical and would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.
In the Relief Request submitted per the May 2, 2013 letter, Ameren Missouri provided justification for the requested relief, as well as a proposed alternative approach to the required leakage testing.
Drawings were also provided as an attachment to the letter. Ameren Missouri has determined, however, that additional information should be provided to facilitate the NRC's review of the Relief Request. The additional infonnation is hereby provided as Attachment 1 to this letter. In addition, the isometric drawing provided as one of the two drawings attached to the May 2, 2013 letter has been
......................................................................................................................... PO Box 620 Fulton, MO 65251 AmerenMissouri.com
ULNRC-05990 May 6, 2013 Page 2 revised to reflect an additional two to three feet of inaccessible piping. The revised drawing is provided as Attachment 2.
As noted in Ameren Missouri's May 2, 2013 letter, NRC verbal approval ofReliefRequest BR-14 is being sought dming the cunent refueling outage at Callaway. This supplemental letter is intended to supp01t prompt verbal approval upon receipt of the letter by the NRC.
No new regulatory commitments have been made or identified in this letter or its attachments. For any questions you may have regarding this request, please contact me at 573-544-8272 or Tom Elwood at 314-225-1905.
Mark A. McLachlan Director Engineering Services TBE/JAD/nls : Supplemental Information Regarding 10 CFR 50.55a Request BR-14 : Isometric Drawing (Revised)
ULNRC-05990 May 6, 2013 Page 3 cc: Mr. Arthur T. Howell Regional Administrator U.S. Nuclear Regulatory Commission Region IV 612 E. Lamar Blvd., Suite 400 Arlington, TX 76011-4125 Senior Resident Inspector Callaway Resident Office U.S. Nuclear Regulatory Commission 8201 NRC Road Steedman, MO 65077 Mr. Fred Lyon Project Manager, Callaway Plant Office ofNuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop 0-8014 Washington, DC 20555-2738 Mr. James T. Polickoski Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Mail Stop 0-8B 1A Washington, DC 20555-2738
ULNRC-05990 May 6, 2013 Page4 Index and send hat*dcopy to QA File Al60.0761 Hardcopy:
Cetirec Corporation 4200 South Hulen, Suite 422 Fort Worth, TX 76109 (Certrec receives ALL attachments as long as they are non-safeguards and may be publicly disclosed.)
Electronic distribution for the following can be made via Other Situations ULNRC Distribution:
A. C. Heflin F. M. Diya C. 0. Reasoner III L. H. Graessle M. A. McLachlan S. A. Maglio L. H. Kanuckel G. S. Kremer NSRB Secretary R. Holmes-Bobo T. B. Elwood J. A. Doughty M.G. Hoehn STARS Regulatory Affairs Mr. John O'Neill (Pillsbury Winthrop Shaw Pittman LLP)
Missouri Public Service Commission
Attachment I to ULNRC-05990 Page I of4 Supplemental Information Regarding 10 CFR 50.55a Request 13R-14
Attachment I to ULNRC-05990 Page 2 of4 The following supplemental infonnation is provided in support of 10 CFR 50.55a Request 13 R-14 concerning leakage testing of the reactor pressure vessel head flange leakofflines as required per Paragraph IWC-5221 ofthe American Society of Mechanical Engineers (ASME) Boiler and Pressure Vesse! Code,Section XI.
Reference 1: Ameren Missouri Letter ULNRC-05986, "1 0 CFR 50.55a Request:
Proposed Alternative to ASME Section XI Requirements for Leakage Testing of Reactor Pressure Vessel Head Flange Leak off Lines (Relief Request BR-14)," dated May 2, 2013 Clarification of ASME Section XI Code Requirements:
Callaway is currently in its third Inservice Inspection Interval, which began December 19, 2004. At the time of this submittal, Refuel 19 is in progress, which is the first refuel of the third inspection period of the interval. The applicable Code is the American Society of Mechanical Engineers (ASME)
Section XI, 1998 Edition with 2000 Addenda. Relief is being requested from certain requirements of the pressure test directed by Table IWC-2500-1, Code Category C-H, Item Number C7.10.
Specifically, request is being sought from the requirements in IWC-5221, "Pressure."
Design Parameters of the Subject Piping and Components:
The system affected by this request consists of the ASME III Class 2 reactor pressure vessel (RPV) flange leak-offlines BB-075-BCB, BB-076-BCB, BB-077-BCB, and their associated valves. This system has design pressure and temperature ratings, and service pressure and temperature conditions (should the inner RPV 0-ring fail), of 650°F and 2485 psig, and 618°F and 2235 psig, respectively.
These are the same design and service conditions as the ASME III Class 1 loop piping.
Accessibility of the Subject piping for direct visual examination:
The total length of pipe from the inner monitor tube, line BB-076-BCB, to the point where the line tees with the outer monitor tube, line BB-075-BCB, is 71 feet. The total length of pipe from the outer monitor tube, line BB-075-BCB, to valve BBHV8032, which is the outermost limit of the system subject to the pressure test, is 79 feet. Included in the 79 feet of pipe run is tubing line BB-077-BCB and the line to drain valve BBV0081. Note that temperature element BBTE040 1, used to detect leakage from the reactor vessel 0-rings, is located 1 foot downstream ofBBHV8032.
Attachment I to ULNRC-05990 Page 3 of4 Lines BB-075-BCB and BB-076-BCB run parallel to each other and are each inaccessible for the first 32 feet due to being located in the annulus area between the reactor vessel and the primary shield wall.
The annulus area can only be accessed by way of the refueling cavity, which is tilled with water dming this test, and by way of the incore tunnel underneath the reactor vessel, which during refueling operations is prohibited fi:om being entered due to the high dose rates from the incore flux mapping thimbles being withdrawn from the reactor vessel.
Lines BB-075-BCB and BB-076-BCB exit the primary shield wall at an elevation of about 14 feet above the floor and travel horizontally along the wall for 22 feet until they drop down and exit the bioshield wall through a penetration that is about five feet off the floor. The line is uninsulated through this area and is visible, including inside the bioshield wall penetration, except for an approximately one foot section in a comer where direct sight is blocked by another line. The line outside of the bioshield, up to and including valve BBHV8032, is insulated and is about 5 feet off the floor.
Service History of the Subject Piping and Components:
Callaway's work history, as well as corrective action history was reviewed for service-related failures of the subject piping and component. The review identified no occurrences ofleakage or other failures on these components. This system does have 21 socket welds, 8 of which are inaccessible behind the primary shield wall, with the rest located outside of the bioshield wall.
Supplemental Information Regarding Performance of the Requested Alternate Pressure Test:
The mandated pressure for the system per IWC-5221 is that pressure developed while the system, or portion of the system, is in service performing its normal operating function or at the system pressure developed during a test conducted to verify system operability. For the subject piping, the pressure developed while the system is performing its normal operating function, i.e., directing leakage from failed RPV flange 0-rings to the reactor coolant drain tank (RCDT), would be RCS pressure (2235 psig).
During the proposed test, the pressure that this system will be subject to during the VT -2 examination will be due to the height of the water in the refueling cavity. The refueling cavity is filled to a minimum of 23 feet of water above the RPV flange for refueling activities. Therefore, the flange, located at plant elevation 2021 feet 7 inches, will see a pressure of at least 10 pounds per square inch.
As the piping travels down to the RCDT, the resultant static head pressure would increase. The lowest portion of the piping is at plant elevation 2005 feet 6 inches, and would experience a pressure of approximately 17 pounds per square inch.
To ensure the lines are clear of air prior to perfonnance of the VT-2 examination, the surveillance instructions have been revised to include a flush oflines BB-075-BCB and BB-076-BCB, after which
Attachment I to ULNRC-05990 Page 4 of4 a four-hour hold is required. Per the surveillance, the flush of the lines is accomplished by attaching a drain hose to the flange downstream ofvalve BBV0081, and then flushing lines BB-075-BCB and BB-076-BCB each for the greater of either 5 minutes or until no air is seen coming from the drain hose.
The pressure test with the VT-2 examination is expected to occur on May 7, 2013. With the refueling pool having been filled on April 13, 2013, the line will have been subject to water and pressure for 24 days.
to ULNRC-05990 Page 1 of2 Attachment 2 Isometric Drawing (Revised)